There’s no way in the ILR for ESFA to see progress towards 20%, so, um, no.
The only current place where holding back of money is happening is if you haven’t recorded sufficient employer contribution by the time a learner completes, at which point you don’t get the completion payment until you can show those payments in your ILR.
There’s no way for ESFA to calculate the minimum OTJ, as we don’t report weekly hours. They won’t be able to use Actual OTJ either, because it’s completely possible to record a Planned OTJ that is higher than the minimum, and the Actual OTJ to then be less than Planned, but more than minimum.
If an apprentice hasn’t done the calculated minimum 20% by the end, just be aware that this doesn’t count as a valid apprenticeship and, if this were discovered if audited, you could theoretically forfeit the entirety of the funding for that apprentice. I don’t know if that happens in reality.
Jaci – Why should the EPAO care about OTJ hours? An apprentices should have done all their OTJ by the time they come to EPA. If not the EPAO’s responsibility to police providers’ adherence to the rules. If we’ve put them in for EPA without sufficient OTJ, that’s our problem.